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Dear Task Force Chairs Newman and Saunders: The undersigned organizations and individuals write to offer recommendations to the Automated Decision Systems Task Force, which is mandated by Local Law 49 of 2018. This is an important opportunity to ensure that emerging technologies, like automated decisions systems, are adopted and implemented fairly and equitably to serve all New Yorkers.

This paper explains the capabilities and limitations of tools for analyzing the text of social media posts and other online content. It is intended to help policymakers understand and evaluate available tools and the potential consequences of using them, and focuses specifically on the use of natural language processing (NLP) tools for analyzing the text of social media posts.

R&D teams in wearable technology can and should also be laboratories of privacy and ethical research best practices. Some companies, such as Fitbit, leverage the talent and expertise on their teams to embed privacy into their technology. Through collaboration with Fitbit, the Center for Democracy & Technology (CDT) examined the procedures and practices within internal R&D teams that result in positive experiences for users, while improving the analytics and hardware behind the technology. Through interviews, surveys, and other research, CDT gained insight into industry-wide trends and best practices.

Privacy questions arise due to the volume and sensitivity of health data generated by consumer-focused apps, devices, and platforms, including the potential analytics uses that can be made of such data. Transparency about data practices is essential not just as a fundamental element of privacy, but is also key to engendering consumer trust, which in turn is critical to the adoption of these services. Without trust, consumers will resist using apps or devices and the industry as a whole will suffer. Overall, transparency practices should be guided by the principle that the consumer should not be surprised. The more unexpected or potentially objectionable a data collection or usage is, the greater the obligation to explain it to consumers.